ACQUISITION.TECHNOLOGYAND LOGISTICS

THE UNDER SECRETARY OF DEFENSE3010 DEFENSE PENTAGON

WASHINGTON, DC 20301-3010

APR - 8 ZOO9

MEMORANDUM FOR SECRETARIES OF THE MILITARY DEPARTMENTS

SUBJECT: Minimizing the Use of Hexavalent Chromium (Cr)

Cr6+ is a significant chemical in numerous Department of Defense (DoD) weapons

systems and platforms due to its corrosion protection properties. However, due to theserious human health and environmental risks related to its use, national and internationalrestrictions and controls are increasing. These restrictions will continue to increase theregulatory burdens and life cycle costs for DoD and decrease materiel availability. OSD,DoD Components, and industry have made substantial investments in finding suitablereplacements for Cr6

+ for many of the current DoD applications. In particular, a numberof defense-related industries are minimizing or eliminating the use of Cr6

+ where provensubstitutes are available that provide acceptable performance for the application.

This is an extraordinary situation that requires DoD to go beyond establishedhazardous materials management processes. To more aggressively mitigate the uniquerisks to DoD operations now posed by Cr6

+, I direct the DoD Military Departments totake the following actions:

• Invest in appropriate research and development on substitutes.• Ensure testing and qualification procedures are funded and conducted to

qualify technically and economically suitable substitute materials andprocesses.

• Approve the use of alternatives where they can perform adequately for theintended application and operating environment. Where Cr6

+ is produced as aby-product from use or manufacture of other acceptable chromium oxides,explore methods to minimize Cr6

+ production.• Update all relevant technical documents and specifications to authorize use of

the qualified alternatives and, therefore, minimize the use of materialscontaining Cr6

+.

• Document the system-specific Cr risks and efforts to qualify less toxicalternatives in the Programmatic Environment, Safety, and OccupationalHealth Evaluation for the system. Analyses should include any cost/schedulerisks and life cycle cost comparisons among alternatives. Life cyclecomparisons should address material handling and disposal costs and systemoverhaul cycle times/costs due to any differences in corrosion protection.

• Share knowledge derived from research, development, testing and evaluations(RDT&E) and actual experiences with qualified alternatives,

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• Require the Program Executive Office (PEO) or equivalent level, incoordination with the Military Department's Corrosion Control and PreventionExecutive (CCPE), to certify there is no acceptable alternative to the use ofCr6

+ on a new system. This requirement also applies to the operation andmaintenance of a system during the Operations and Support phase of asystem's life cycle. The PEO or equivalent, in coordination with the MilitaryDepartment's CCPE, shall evaluate each certification for validity, taking intoaccount at a minimum the following:

o Cost effectiveness of alternative materials or processes.o Technical feasibility of alternative materials or processes.o Environment, safety, and occupational health risks associated with the use

of the Cr6+ or substitute materials in each specific application.

o Achieving a Manufacturing Readiness Level of at least 8 for any qualifiedalternative.

o Materiel availability of Cr6+ and the proposed alternatives over theprojected life span of the system.

o Corrosion performance difference of alternative materials or processes asdetermined by agency corrosion subject matter experts.

• For such applications where acceptable alternatives to Cr6+ do not exist, Cr6+

may be used.

The Defense Acquisition Regulation Council will prepare a clause for defensecontracts prohibiting use of Cr6

+ containing materials in all future procurements unlessspecifically approved by the Government. When applied in weapon system design,procurement, and logistics support contracts, the requirement will apply at system,subsystem, and component level.

The DoD "Advanced Surface Engineering Technologies for a SustainableDefense" database will be expanded to facilitate knowledge management on RDT&E andexperiences using alternatives. The Strategic Environmental Research and DevelopmentProgram office will provide further information on accessing this database.

As DoD's supply chain integrator, the Defense Logistics Agency will assist theServices in their efforts to eliminate Cr6

+ from corrunon hardware and DLA-manageditems.

This policy applies to all new program starts, new program increments, andprocurement of infrastructure materials, goods, and services. Application of this policyto legacy systems will be limited to modifications where alternatives can be inserted inthe system modification process and updated maintenance procedures.

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The Military Departments are to provide a report to my office by April 2010 thatdescribes the implementation actions taken to minimize CR6+. Please provide a point ofcontact to my office for this initiative within 30 days from the date of this memorandum.My point of contact is Ms. Shannon Cunniff at 703-604-0641 or shannon.cunniff@osd.mil.

cc:Chairman of the Joint Chiefs of StaffUnder Secretary of Defense for Personnel and ReadinessCommander, U.S. Special Operations CommandDeputy Under Secretary of Defense for Acquisition and TechnologyDeputy Under Secretary of Defense for Logistics and Material ReadinessDirector for Defense Research and EngineeringDirector, Operational Test and EvaluationDirectors of the Defense AgenciesDirector, Acquisition Resources and AnalysisDirector, Corrosion Policy Oversight Office

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